UK CBAM from 2027 for exporters: goods, £50,000 threshold, emissions data

What UK CBAM is and which goods it covers

The UK government will introduce a carbon border adjustment mechanism on 1 January 2027 for goods in the aluminium, cement, fertiliser, hydrogen, and iron and steel sectors. The glass and ceramic sectors will not be in scope from 2027. HMRC publishes lists of commodity codes for each sector, so the first check is whether the commodity code of your goods is on the list.

The charge applies per tonne of embodied emissions at a CBAM rate that reflects the UK Emissions Trading Scheme (UK ETS) and its free allowances. The importer can use independently verified actual emissions data or default emission values, and the liability can be reduced if the embodied emissions were subject to a deductible carbon price overseas.

Who is the importer, and the £50,000 threshold

The liable person is the person responsible for completing the customs declaration, or the person on whose behalf it is made. HMRC's guidance says you are the importer if you are named on the import declaration, even if a tax agent, freight forwarder, haulier, customs broker, express operator or fast parcel operator declares the goods for you, and the importer can be established in the UK or outside it. An exporter that sells DDP and is named on the UK import declaration is therefore the CBAM importer.

Registration is needed once CBAM goods worth £50,000 or more have been imported in the previous 12 months, checked on a rolling basis on the first day of each month, or from the day you know you will import £50,000 or more within the next 30 days.

• Goods for private use and goods of UK origin are exempt and do not count towards the threshold.
• Re-imported goods with returned goods relief do not count.
• Goods under temporary admission with full relief, and goods under inward or outward processing, in freeport customs sites, under authorised use or in customs warehousing do not count, unless they are released into free circulation with customs duty due.
• Under conditions, Union goods exported from Northern Ireland to the EU and re-imported into the UK do not count.

Returns and payment

The first accounting period is annual, from 1 January to 31 December 2027, with payment due at the end of May 2028. After that, accounting periods are quarterly.

What exporters should prepare for UK buyers

HMRC tells importers that they will get the emissions evidence from their supplier as a verification report or verification summary containing the relevant emissions data, and that they must keep it for 6 years. If the importer claims relief for a carbon price paid overseas, it needs a carbon pricing verification form completed by a suitable verifier. Importers also keep the 8-digit commodity code and description, the date of the tax point, the value and weight of each import, and evidence of any exemption.

• Confirm the commodity code of each product against HMRC's sector lists.
• Measure the embodied emissions of each product and have them verified, so you can give the buyer a verification report or summary.
• Collect evidence of any carbon price paid in your country, for the carbon pricing verification form.
• Show the commodity code, net weight and value clearly on the commercial invoice and packing list.
• If you sell DDP, plan to register for UK CBAM yourself when your sales reach the threshold.